Key Takeaways
- • The North Dakota Retirement and Investment Office launched legacyfund.nd.gov, a public website detailing the investments and performance of the state's roughly $15 billion Legacy Fund, built by Washington, D.C.-based Tactis with Fargo-based Devii as local subcontractor under a five-year maintenance contract.
- • According to the website, $11.17 billion (74%) of holdings is assigned to a country, while $3.89 billion (26%) sits in pooled, multiregion commingled vehicles whose underlying holdings are not publicly disclosed.
- • Rep. Bernie Satrom, the primary sponsor of 2025 House Bill 1319, says the site falls short of its transparency goal, noting much of the data was already obtained through open records requests despite hundreds of thousands of dollars spent.
- • North Dakota Attorney General Drew Wrigley sided with the RIO, ruling the office is not legally required under open records law to create a record of countries where commingled fund managers invest.
- • Satrom plans to revisit the commingled funds policy during the 2027 legislative session, while Gov. Kelly Armstrong and Rep. Jonathan Warrey favor balancing transparency against access to investment opportunities.
Summary
The website includes a history of the fund, growth data, a breakdown of the in-state investment program, and an interactive world map showing investments by country. Users can filter holdings by asset class and sector, search by company name, and download the data. Gov. Kelly Armstrong called the site "great," arguing it provides enough detail to dig into regions, countries and investment types without overwhelming users with micro-level data.
Rep. Bernie Satrom, R-Jamestown, the primary sponsor of House Bill 1319 passed in the 2025 session to boost transparency, said the site does not meet that goal. He described the site as attractive and more convenient but noted much of its information was already available through open records requests, questioning whether the state is meaningfully closer to knowing where its money is invested after spending hundreds of thousands of dollars. Per the website, $11.17 billion, or 74% of holdings, is assigned to a country, while $3.89 billion, or 26%, is held in pooled multiregion vehicles not assigned to any country. Much of this money is commingled with other investors' capital. The RIO has said commingled funds allow it to leverage less capital for greater returns, though the managers are disclosed while their underlying holdings are not. Satrom asked why roughly one in five dollars remains outside public view.
The Tribune previously requested records on commingled fund locations and was told no such record exists. Attorney General Drew Wrigley sided with the RIO in a recent opinion, finding the office has no record of the countries where banks managing those funds invest and is therefore not obligated under open records law to create one. Satrom also raised concerns that the fund may still hold Russian government debt or investments tied to the Chinese military. The Forum of Fargo-Moorhead reported in 2022 that the fund had $8.5 million in investments with Russian ties, part of $44 million in total state investments with such ties.
Armstrong said he would like to see commingled investments reduced over time but does not want to forgo opportunities, and Rep. Jonathan Warrey, R-Casselton, said the policy requires balance. Satrom said he will seek to revisit the commingled funds policy in the 2027 legislative session.
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